T.C. Memo. 2002-315 UNITED STATES TAX COURT CHRISTOPHER KILEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6676-02L. Filed December 27, 2002. Christopher Kiley, pro se. Rollin G. Thorley and Robin Ferguson, for respondent. MEMORANDUM OPINION ARMEN, Special Trial Judge: This matter is before the Court on respondent’s Motion For Summary Judgment And To Impose A Penalty Under I.R.C. Section 6673, filed pursuant to Rule 121.1 Respondent contends that there is no dispute as to any material 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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